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August 23, 2022

Emotet Resurgence: Cross-Industry Analysis

Technical insights on the Emotet resurgence in 2022 across various client environments, industries, and regions.
Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Eugene Chua
Cyber Security Analyst
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23
Aug 2022

Introduction

Last year provided further evidence that the cyber threat landscape remains both complex and challenging to predict. Between uncertain attribution, novel exploits and rapid malware developments, it is becoming harder to know where to focus security efforts. One of the largest surprises of 2021 was the re-emergence of the infamous Emotet botnet. This is an example of a campaign that ignored industry verticals or regions and seemingly targeted companies indiscriminately. Only 10 months after the Emotet takedown by law enforcement agencies in January, new Emotet activities in November were discovered by security researchers. These continued into the first quarter of 2022, a period which this blog will explore through findings from the Darktrace Threat Intel Unit. 

Dating back to 2019, Emotet was known to deliver Trickbot payloads which ultimately deployed Ryuk ransomware strains on compromised devices. This interconnectivity highlighted the hydra-like nature of threat groups wherein eliminating one (even with full-scale law enforcement intervention) would not rule them out as a threat nor indicate that the threat landscape would be any more secure. 

When Emotet resurged, as expected, one of the initial infection vectors involved leveraging existing Trickbot infrastructure. However, unlike the original attacks, it featured a brand new phishing campaign.

Figure 1: Distribution of observed Emotet activities across Darktrace deployments

Although similar to the original Emotet infections, the new wave of infections has been classified into two categories: Epochs 4 and 5. These had several key differences compared to Epochs 1 to 3. Within Darktrace’s global deployments, Emotet compromises associated to Epoch 4 appeared to be the most prevalent. Affected customer environments were seen within a large range of countries (Figure 1) and industry verticals such as manufacturing and supply chain, hospitality and travel, public administration, technology and telecoms and healthcare. Company demographics and size did not appear to be a targeting factor as affected customers had varying employee counts ranging from less than 250, to over 5000.

Key differences between Epochs 1-3 vs 4-5

Based on wider security research into the innerworkings of the Emotet exploits, several key differences were identified between Epochs 4/5 and its predecessors. The newer epochs used:

·       A different Microsoft document format (OLE vs XML-based).

·       A different encryption algorithm for communication. The new epochs used Elliptic Curve Cryptograph (ECC) [1] with public encryption keys contained in the C2 configuration file [2]. This was different from the previous Rivest-Shamir-Adleman (RSA) key encryption method.

·       Control Flow Flattening was used as an obfuscation technique to make detection and reverse engineering more difficult. This is done by hiding a program’s control flow [3].

·       New C2 infrastructure was observed as C2 communications were directed to over 230 unique IPs all associated to the new Epochs 4 and 5.

In addition to the new Epoch 4 and 5 features, Darktrace detected unsurprising similarities in those deployments affected by the renewed campaign. This included self-signed SSL connections to Emotet’s new infrastructure as well as malware spam activities to multiple rare external endpoints. Preceding these outbound communications, devices across multiple deployments were detected downloading Emotet-associated payloads (algorithmically generated DLL files).

Emotet Resurgence Campaign

Figure 2: Darktrace’s Detection Timeline for Emotet Epoch 4 and 5 compromises

1. Initial Compromise

The initial point of entry for the resurgence activity was almost certainly via Trickbot infrastructure or a successful phishing attack (Figure 2). Following the initial intrusion, the malware strain begins to download payloads via macro-ladened files which are used to spawn PowerShell for subsequent malware downloads.

Following the downloads, malicious communication with Emotet’s C2 infrastructure was observed alongside activities from the spam module. Within Darktrace, key techniques were observed and documented below.

2. Establish Foothold: Binary Dynamic-link library (.dll) with algorithmically generated filenames 

Emotet payloads are polymorphic and contain algorithmically generated filenames . Within deployments, HTTP GET requests involving a suspicious hostname, www[.]arkpp[.]com, and Emotet related samples such as those seen below were observed:

·       hpixQfCoJb0fS1.dll (SHA256 hash: 859a41b911688b00e104e9c474fc7aaf7b1f2d6e885e8d7fbf11347bc2e21eaa)

·       M0uZ6kd8hnzVUt2BNbRzRFjRoz08WFYfPj2.dll (SHA256 hash: 9fbd590cf65cbfb2b842d46d82e886e3acb5bfecfdb82afc22a5f95bda7dd804)

·       TpipJHHy7P.dll (SHA256 hash: 40060259d583b8cf83336bc50cc7a7d9e0a4de22b9a04e62ddc6ca5dedd6754b)

These DLL files likely represent the distribution of Emotet loaders which depends on windows processes such as rundll32[.]exe and regsvr32[.]exe to execute. 

3. Establish Foothold: Outbound SSL connections to Emotet C2 servers 

A clear network indicator of compromise for Emotet’s C2 communication involved self-signed SSL using certificate issuers and subjects which matched ‘CN=example[.]com,OU=IT Department,O=Global Security,L=London,ST=London,C=GB’ , and a common JA3 client fingerprint (72a589da586844d7f0818ce684948eea). The primary C2 communications were seen involving infrastructures classified as Epoch 4 rather than 5. Despite encryption in the communication content, network contextual connection details were sufficient for the detection of the C2 activities (Figure 3).

Figure 3: UI Model Breach logs on download and outbound SSL activities.

Outbound SSL and SMTP connections on TCP ports 25, 465, 587 

An anomalous user agent such as, ‘Microsoft Outlook 15.0’, was observed being used for SMTP connections with some subject lines of the outbound emails containing Base64-encoded strings. In addition, this JA3 client fingerprint (37cdab6ff1bd1c195bacb776c5213bf2) was commonly seen from the SSL connections. Based on the set of malware spam hostnames observed across at least 10 deployments, the majority of the TLDs were .jp, .com, .net, .mx, with the Japanese TLD being the most common (Figure 4).

Figure 4: Malware Spam TLDs observed in outbound SSL and SMTP

 Plaintext spam content generated from the spam module were seen in PCAPs (Figure 5). Examples of clear phishing or spam indicators included 1) mismatched personal header and email headers, 2) unusual reply chain and recipient references in the subject line, and 3) suspicious compressed file attachments, e.g. Electronic form[.]zip.

Figure 5: Example of PCAP associated to SPAM Module

4. Accomplish Mission

 The Emotet resurgence also showed through secondary compromises involving anomalous SMB drive writes related to CobaltStrike. This consistently included the following JA3 hash (72a589da586844d7f0818ce684948eea) seen in SSL activities as well as SMB writes involving the svchost.exe file.

Darktrace Detection

 The key DETECT models used to identify Emotet Resurgence activities were focused on determining possible C2. These included:

·       Suspicious SSL Activity

·       Suspicious Self-Signed SSL

·       Rare External SSL Self-Signed

·       Possible Outbound Spam

File-focused models were also beneficial and included:

·       Zip or Gzip from Rare External Location

·       EXE from Rare External Location

Darktrace’s detection capabilities can also be shown through a sample of case studies identified during the Threat Research team’s investigations.

Case Studies 

Darktrace’s detection of Emotet activities was not limited by industry verticals or company sizing. Although there were many similar features seen across the new epoch, each incident displayed varying techniques from the campaign. This is shown in two client environments below:

When investigating a large customer environment within the public administration sector, 16 different devices were detected making 52,536 SSL connections with the example[.]com issuer. Devices associated with this issuer were mainly seen breaching the same Self-Signed and Spam DETECT models. Although anomalous incoming octet-streams were observed prior to this SSL, there was no clear relation between the downloads and the Emotet C2 connections. Despite the total affected devices occupying only a small portion of the total network, Darktrace analysts were able to filter against the much larger network ‘noise’ and locate detailed evidence of compromise to notify the customer.

Darktrace also identified new Emotet activities in much smaller customer environments. Looking at a company in the healthcare and pharmaceutical sector, from mid-March 2022 a single internal device was detected making an HTTP GET request to the host arkpp[.]com involving the algorithmically-generated DLL, TpipJHHy7P.dll with the SHA256 hash: 40060259d583b8cf83336bc50cc7a7d9e0a4de22b9a04e62ddc6ca5dedd6754b (Figure 6). 

Figure 6: A screenshot from VirusTotal, showing that the SHA256 hash has been flagged as malicious by other security vendors.

After the sample was downloaded, the device contacted a large number of endpoints that had never been contacted by devices on the network. The endpoints were contacted over ports 443, 8080, and 7080 involving Emotet related IOCs and the same SSL certificate mentioned previously. Malware spam activities were also observed during a similar timeframe.

 The Emotet case studies above demonstrate how autonomous detection of an anomalous sequence of activities - without depending on conventional rules and signatures - can reveal significant threat activities. Though possible staged payloads were only seen in a proportion of the affected environments, the following outbound C2 and malware spam activities involving many endpoints and ports were sufficient for the detection of Emotet.

 If present, in both instances Darktrace’s Autonomous Response technology, RESPOND, would recommend or implement surgical actions to precisely target activities associated with the staged payload downloads, outgoing C2 communications, and malware spam activities. Additionally, restriction to the devices’ normal pattern of life will prevent simultaneously occurring malicious activities while enabling the continuity of normal business operations.

 Conclusion 

·       The technical differences between past and present Emotet strains emphasizes the versatility of malicious threat actors and the need for a security solution that is not reliant on signatures.

·       Darktrace’s visibility and unique behavioral detection continues to provide visibility to network activities related to the novel Emotet strain without reliance on rules and signatures. Key examples include the C2 connections to new Emotet infrastructure.

·       Looking ahead, detection of C2 establishment using suspicious DLLs will prevent further propagation of the Emotet strains across networks.

·       Darktrace’s AI detection and response will outpace conventional post compromise research involving the analysis of Emotet strains through static and dynamic code analysis, followed by the implementation of rules and signatures.

Thanks to Paul Jennings and Hanah Darley for their contributions to this blog.

Appendices

Model breaches

·       Anomalous Connection / Anomalous SSL without SNI to New External 

·       Anomalous Connection / Application Protocol on Uncommon Port 

·       Anomalous Connection / Multiple Connections to New External TCP Port 

·       Anomalous Connection / Multiple Failed Connections to Rare Endpoint 

·       Anomalous Connection / Multiple HTTP POSTs to Rare Hostname 

·       Anomalous Connection / Possible Outbound Spam 

·       Anomalous Connection / Rare External SSL Self-Signed 

·       Anomalous Connection / Repeated Rare External SSL Self-Signed      

·       Anomalous Connection / Suspicious Expired SSL 

·       Anomalous Connection / Suspicious Self-Signed SSL

·       Anomalous File / Anomalous Octet Stream (No User Agent) 

·       Anomalous File / Zip or Gzip from Rare External Location 

·       Anomalous File / EXE from Rare External Location

·       Compromise / Agent Beacon to New Endpoint 

·       Compromise / Beacon to Young Endpoint 

·       Compromise / Beaconing Activity To External Rare 

·       Compromise / New or Repeated to Unusual SSL Port 

·       Compromise / Repeating Connections Over 4 Days 

·       Compromise / Slow Beaconing Activity To External Rare 

·       Compromise / SSL Beaconing to Rare Destination 

·       Compromise / Suspicious Beaconing Behaviour 

·       Compromise / Suspicious Spam Activity 

·       Compromise / Suspicious SSL Activity 

·       Compromise / Sustained SSL or HTTP Increase 

·       Device / Initial Breach Chain Compromise 

·       Device / Large Number of Connections to New Endpoints 

·       Device / Long Agent Connection to New Endpoint 

·       Device / New User Agent 

·       Device / New User Agent and New IP 

·       Device / SMB Session Bruteforce 

·       Device / Suspicious Domain 

·       Device / Suspicious SMB Scanning Activity 

For Darktrace customers who want to know more about using Darktrace to triage Emotet, refer here for an exclusive supplement to this blog.

References

[1] https://blog.lumen.com/emotet-redux/

[2] https://blogs.vmware.com/security/2022/03/emotet-c2-configuration-extraction-and-analysis.html

[3] https://news.sophos.com/en-us/2022/05/04/attacking-emotets-control-flow-flattening/

Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Eugene Chua
Cyber Security Analyst

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July 7, 2026

Securing AI: Analysis of the Complete Security Stack with Governance and Controls

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Why traditional cybersecurity approaches are not enough for AI

AI adoption outpaces most security programs’ ability to adapt.  That gap is now one of the most consequential sources of cyber risk facing enterprises. As organizations embed generative and agentic AI into development workflows, business operations, and security tooling itself, the question is no longer whether AI will introduce risk. The question is whether organizations understand where that risk actually lives and how to manage it operationally.  

Two recent pieces of guidance underscore this shift:

  1. The upcoming Cybersecurity Framework Profile for AI from NIST
  1. The Five Eyes government guidance on the careful adoption of agentic AI services

Taken together, they point to a critical conclusion. AI security cannot be reduced to model hardening or prompt filtering. It requires a defense in depth strategy that treats AI as both a new attack surface and a force multiplier for defense, while accounting for how AI fundamentally changes scale, speed, and autonomy.  

Recent threat research suggests that today's cyber risk is driven less by initial compromise and more by an adversary's ability to blend into normal operations over time. AI systems create the same exposure in a new form: more autonomy, more scale, and more opportunities for risky behavior to blend into normal operations.

How NIST defines the three core pillars of AI security

The NIST profile organizes AI risk across three inseparable focus areas that span all cybersecurity functions, Secure, Defend and Thwart. These areas are not sequential. They exist simultaneously and must be addressed together.

Secure

This treats AI as an attack surface. It includes models, prompts, agents, pipelines, training and inference data, retrieval augmented generation corpora, and the AI supply chain itself. AI systems are opaque, probabilistic, and non-deterministic by design. Some vulnerabilities are inherent in how models are trained or how data is sourced. Traditional patching does not fully mitigate these risks. This is also where many enterprises are weakest today and, critically, where many security programs stop.  

Defend

This is AI as a defensive force multiplier. AI can improve detection speed, scale, correlation, and response, but only if the right models are used and operationalized correctly. Machine-speed behavior-based detection, response and containment becomes critical in defending non-deterministic systems. Accuracy, explainability, governance, testing, validation, and integration into SOC workflows matter as much as capability. Without those controls, hallucination risk, over automation, and misplaced trust become security risks themselves.  

Thwart

This treats AI as an adversarial accelerant. Threat actors are already using AI to generate targeted social engineering attacks, deepfakes, malware, and autonomous attack agents. Asymmetric warfare is highlighting faster vulnerability discovery and exploitation with a lag on patch development, testing and deployment.  

How this looks in practice

Darktrace researchers observed scaled, automated exploitation of the React2Shell vulnerability within days of disclosure. A vulnerable cloud asset was exploited in under 120 seconds of being deployed. Darktrace research team observed an AI/LLM-generated malware sample used in exploitation activity tied to React2Shell. The significance isn't novelty. It is that AI lowers the barrier to producing usable offensive tooling and compresses the time between experimentation and deployment.  

Tactics are getting more and more creative in order to string together steps of an attack kill chain. This creates a dependency on behavior-based detection, autonomous investigation, autonomous containment, training, resilience investment, and recovery planning across the entire enterprise.

Why agentic AI fundamentally changes enterprise cyber risk

The Five Eyes guidance on agentic AI highlights material changes to the cyber risk profile of an organization. Unlike generative AI systems that produce content for human consumption, agentic AI systems reason, plan, and act autonomously across tools, data, and environments. That autonomy, combined with access to real systems, amplifies the impact of traditional cyber failures and introduces new system level risks that are difficult to predict, observe, and contain.  

Risk in agentic systems does not live in the model alone. It emerges from interactions between models, prompts, memory, tools, APIs, identities, privileges, inter-agent trust relationships, and human assumptions baked into design. Vulnerabilities are often introduced through data, connectors, natural language interfaces, protocols, and drift by design.

In supply-chain incidents, attackers did not need sophisticated exploits to scale impact. They abused trusted systems built for automation and implicit access. Agentic AI inherits that model. Once a system can act across tools, data, and workflows, compromise propagates through trust relationships that were never designed for machine autonomy.

The major agentic AI risk classes include the following:  

  • The identity control for non-human identities or autonomous agents makes it difficult to mitigate over-permissioning, limiting access, scope, and duration, as well as access hygiene
  • Agents are frequently over permissioned
  • Compromised tools inherit agent authority
  • Static secrets enable impersonation
  • Implicit trust between agents enables lateral movement

Design and configuration risks compound this, including privileges evaluated once at startup, poor segmentation, unvetted third party tools, reused authorization decisions outside their original context, and guardrail limitations.  

Behavioral risk  

Agents can optimize for goals in unsafe ways, misinterpret ambiguous intent, chain actions into unintended sequences, change behavior during evaluation, and exhibit deceptive or sycophantic responses.  

Structural risk  

Structural risk follows from agentic systems that are tightly coupled, multicomponent ecosystems. Failures can propagate across agents. Hallucinations cascade downstream. Resource exhaustion becomes systemic. Tool misuse enables indirect prompt injection and command execution. Rogue agents can poison peer agents through trust relationships.  

Accountability

Accountability becomes unclear as autonomy increases. Autonomous agents assume human identity permissions, and humans should have clear ownership of these agents, but they don’t, and this model is flawed. Decision paths are opaque and non-deterministic. Logs are fragmented and difficult to interpret. Reproducing an incident will be impossible without explicit design for observability and forensics. An agent compromise is functionally an insider threat, often with better access and fewer behavioral constraints than a human.  

What does defense in depth look like for AI?

Agentic AI runs on software, networks, identities, and data. It must be governed using the same foundational principles that have proven resilient under uncertainty, including secure by design, defense in depth, zero trust, least privilege, continuous monitoring, behavior-based advanced threat detection and containment, and incident response and recovery.

Core components to a Defense in depth Strategy for Securing the use of AI:

  • Strong, precise identity control plane to include an identity per agent (cryptographic, non‑shared)
    • Privilege monitoring and just‑in‑time access
  • Data Governance
  • Secure‑by‑default configurations
    • Security Posture Management  
    • Zero Trust principles  
  • Strong guardrails, deny‑by‑default policies, and isolation
  • Explicit instruction hierarchies and controlled context
  • Behavioral-based detection across entire enterprise to include inputs, tools, and outputs as well as AI used on the endpoint, across the network, cloud, SaaS, email, and OT
    • Runtime anomaly detection and goal‑drift detection
    • Autonomous containment to mitigate risk and minimize damage
  • Hard boundaries on autonomy and delegation
  • Testing, Evaluation, Validation and Verification  
    • Determine when autonomous action and when human in the loop
    • Adversarial training and agent‑specific testing
    • Simulation, red teaming, and chaos testing
  • Kill‑switches, rollback, and containment mechanisms
    • Forensics data captures, interpretability, autonomous containment, and remediation/recovery plans  

Until standards, tooling, and assurance methods mature, organizations should assume agentic AI systems will behave unexpectedly and design deployments around resilience, behavior-based detection, reversibility, and containment, not efficiency.

How security leaders should prepare for enterprise AI adoption

AI security is not model security alone. Data, pipelines, identities, and agents are first class assets. Many AI attacks succeed through standard cyber failures amplified by AI. Identity, data, and supply chain risk dominate. Behavior-based detection and response are critical, not optional. Logging, provenance, versioning, and forensics data capture of detections are mandatory because you cannot investigate or recover from AI incidents without them.  

Risk will often be visible in behavior before it is clearly defined in policy or guidance. The same pattern has been seen in pre-CVE disclosure detection, where abnormal activity appears before the industry has named or described the vulnerability. AI systems introduce that uncertainty by design.

Security leaders should prioritize controls before AI is fully deployed, avoid generic AI security checklists, integrate AI risk into existing cyber programs, and mitigate the risk of non-deterministic technology with continuous oversight, monitoring, behavior analytics, anomaly detection, autonomous investigation, and autonomous containment.

Visibility has a different connotation with AI. Previously, audit logging worked for software/people, but with Generative AI-based systems, interpretability and explainability is difficult to understand, you cannot "undo" what has been done, or see the logic or control a chain of events. This is why behavioral-based detections and containment becomes critical.  

What capabilities should every AI security program include?

If an organization asked “what must be in place before scaling AI?”:

  1. AI Risk board and approval workflow
  1. IAM + PAM for all AI services and agents
  1. AI asset inventory
  1. Prompt/output DLP with sanctioned AI access – This is not just pre- and post- filters, but behavior-based detections of semantic interface as well as behavior-based analysis of output with associated risk context.  
  1. Shadow AI identification
  1. Secure MLOps – This is an entire paper itself
  1. Runtime guardrails and tool restrictions
    • Including AI Gateway/SASE/Zero trust/
  1. Runtime security with behavior-based detections
    • Complete visibility, monitoring, behavior analytics, anomaly detection, risk/intent/context evaluation of anomalies, autonomous investigation and autonomous containment of all AI assets across endpoint, network, SaaS, SASE, cloud, OT, email, and messaging platforms
  1. Secure data pipelines and data governance
  1. SOC workflow changes from malicious classification workflows to behavior-based detection workflows
  1. Remediation plans for AI-related incidents  

Layered Governance and Security Stack for Securing AI  

The following outline considers governance and security tools that should be considered, well-integrated, deployed, tested, operationalized and embedded within security workflows. These tools and controls map to NIST’s CMF for AI.  

These considerations do not need to be implemented in order. Runtime Detect and Respond will help mitigate risk while Governance, Visibility, and Identity mature.

Category Tooling Controls
Governance & Visibility
  • AI asset inventory / AI CMDB
  • Shadow AI discovery
  • SaaS discovery
  • AI usage on non-endpoint managed systems via network or cloud telemetry
  • MCP server/client usage via protocols
  • Browser telemetry
  • Gateway or SASE telemetry
  • Establish a risk board to set up controls
  • Mandatory registration of AI systems
  • Owner, data classification, intended use, and risk tier
  • Supplier disclosure requirements
  • Risk mitigation plan for AI adoption, innovation, or development
Identity, Access & Agent Control

Non-human autonomous agents should not have the full permissions associated with a human user.

  • IAM with workload identities
  • PAM for AI service accounts
  • Secrets management with short-lived tokens
  • Zero Trust principles
  • Identity, permission, and token hygiene
  • Unique identities per model, agent, and pipeline
  • Least privilege for tools, data, and APIs
  • Explicit approval for autonomous actions
Data Security & Privacy
  • Data classification and labeling
  • Enterprise DLP across endpoint, email, network, cloud, and SaaS
  • Forensics data capture after risky detections
  • Prompt-level DLP through behavior-based semantic analysis with risk and intent context
  • Input/interface analysis for risky data requests
  • Output analysis for sensitive data
  • Data integrity evaluation
  • Retention and redaction policies for prompts and responses
Secure MLOps / LLMOps
  • Secure CI/CD with AI-specific gates
  • Model registries with approval workflows
  • Dependency, container, and artifact scanning
  • SBOM/AIBOM generation
  • IaC security scanning
  • Security posture management
  • Misconfiguration identification
  • Hardening recommendations
  • Signed models and prompts
  • Versioned datasets, configurations, logging, and controls
  • Securing data pipelines
  • Controlled promotion
  • Quality assurance
  • Adversarial testing
Runtime Security

Securing runtime goes beyond guardrails and model firewalls to include behavior-based detections, response, and containment.

  • Detection, monitoring, and SOC integration
  • Centralized visibility into prompts, outputs, and tool calls
  • AI-specific detections
  • Behavior-based detection for AI usage patterns
  • Model drift and behavior monitoring
  • Autonomous containment
  • Behavior-based detection of model inputs and outputs
  • Prompt injection detection
  • Model manipulation, including jailbreaking, poisoning, and related attacks
  • Sensitive data access attempts
  • Behavior-based detection across low-code agents, high-code agents, MCP clients and servers, endpoint, network, cloud, email, SaaS, SASE, IoT, and OT
  • Policy enforcement between users, models, tools, agents, SaaS models/tools, and MCP servers/clients
  • Risk, intent, and context evaluation for detections and response actions
Response & Recovery
  • Autonomous containment
  • AI-assisted playbooks
  • Forensics data capture for AI-related events
  • Model rollback mechanisms
  • Backup and restore for models and datasets
  • Kill switch for agents
  • Autonomous response to agents performing risky behaviors
  • Model and dataset rollback
  • Remediation plans
  • Tabletop exercises
  • Supplier coordination plans
  • Post-incident AI performance validation

AI security requires continuous visibility and behavioral detection

AI changes how fast systems move, how decisions are made, and how risk propagates. It does not change the fundamentals of security. Organizations that succeed will be the ones that apply those fundamentals rigorously, assume failure, and build systems that can detect, contain, and recover when AI behaves in ways they did not anticipate. Security is not what AI is allowed to do. It is whether the organization can understand, trust, and control what AI actually does in practice.  

Take this guidance to understand different initiatives that organizations should be considering. Securing AI is the most critical component to AI safety. As organizations invest more in AI adoption, they should be investing in security in order to mitigate the risk of AI adoption. Organizations should be evaluating their governance and security stack to include well-integrated tools that are deployed, tested, operationalized and embedded within security workflows. While organizations mature in governance, visibility and identity access management, they should be investing in behavior-based detection and autonomous containment to mitigate AI risk.  

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July 6, 2026

NIST Just Proved It: AI Security Can’t Be Solved With Rules

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Static AI guardrails are inherently limited

As organizations adopt generative AI, many still assume that the right set of guardrails will be enough. The problem is you can’t anticipate every way these systems might be misused, abused or attacked. What NIST has done is put a mathematical foundation under that intuition.

In recent research building on Gödel’s incompleteness theorems, which showed that any system built on a fixed set of rules will always have gaps, NIST demonstrates that there is no finite set of guardrails that can be universally robust against adversarial prompts. In plain terms, if your defense is based on a fixed set of rules, there will always be inputs that bypass them. Not because the rules are badly written, but because the problem space is bigger than static rules can ever cover.

This is not new in cybersecurity - detection rules have always had to live with this trade-off. What is different with GenAI is the scale and shape of that problem. These systems are built on human language, and human language is not bounded. It is fluid, contextual and deliberately ambiguous. The number of ways intent can be hidden is effectively limitless. You are not defending against a defined protocol or a fixed exploit chain. You are defending against the entire expressive capacity of people.

So attempting to create a complete set of rules is the wrong starting point. It assumes the problem can be deterministically described. NIST’s work shows that it cannot. Organizations still need a way to manage AI risk, but the traditional approach of defining allowed and disallowed patterns is always going to lag behind what is actually happening. The same input can be benign in one context and risky in another, and static rules struggle to capture that distinction.

The question then is what fills that gap?

AI security must shift from rules to behavior

What's required is a shift in what you are trying to understand. Rules try to describe what should and shouldn't happen. Behavior shows you what is happening. Or to put it another way, if inputs are unbounded and adversaries adapt, the only stable signal is behavior.

In a GenAI context, that means analyzing how an AI model is being used, how prompts evolve over time, how outputs are shaped, and where AI agent interactions start to drift from what is expected. It means moving from static definitions of bad to a more dynamic understanding of intent.

Instead of trying to predict every bad prompt, you focus on identifying when behavior starts to move outside expected norms. Instead of asking whether a single input matches a rule, you ask whether the overall pattern of activity makes sense for the system and how it’s being used.

Guardrails remain important but they are only one layer

This does not eliminate the need for guardrails. They still play a role. But they will never address the entire problem space and are simply one part of your defense in depth approach.

NIST’s proof is useful because it makes this explicit. It removes the assumption that with enough effort, a complete rule set is achievable. It isn’t.

Once you accept that, the shift becomes unavoidable. This is no longer a problem of writing better rules, but of understanding behavior in a space where the possible inputs are effectively unbounded.

For security leaders, that changes the nature of the problem. It is less about defining what should be allowed, and more about recognizing when something is no longer consistent with expected behavior.

That does not remove the need for guardrails, but it does change their role. They set boundaries, but they do not define understanding. The gap between the two is where risk now sits.

In the end, this is what “can’t be solved with rules” really means. Rules will always leave gaps, and those gaps are not theoretical. They show up in how systems actually behave Not what we expect them to do, or what we intended them to do, but what they are doing in practice. That is where the signal is, and increasingly, that is where the security problem sits.

References:

https://www.nist.gov/news-events/news/2026/06/nist-mathematical-proof-supports-transition-continuous-monitor-and-update

https://ieeexplore.ieee.org/document/11475847

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About the author
Andrew Hollister
Principal Solutions Engineer, Cyber Technician
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